Page 17 - FIGI - Big data, machine learning, consumer protection and privacy
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•  Social media data                               decisions (or to provide inputs to human deci-
            •  B2B data acquired from parties in the supply chain  sions). Automated decisions are decisions made by
            •  Agriculture data (e.g., feeds on corn production)  computer processing systems without any human
            •  Point of sale data                              involvement (beyond the coding), typically based
            •  Pharmaceutical prescription data                on inferences produced by profiling using machine
                                                               learning models applied to big data. Inferences and
            The increasing connectivity of devices provides    predictions improve firms’ ability to discriminate
            opportunities for data for financial services provid-  among consumers, offering them products and ser-
            ers. For instance, cars today have extensive comput-  vices suited to their preferences or needs, and at
            ing power, use extensive code, and process huge    prices they are willing to pay. Examples include deci-
            amounts of data.  Lenders increasingly require     sions whether to extend credit to an individual or to
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            borrowers, particularly higher risk (subprime)     offer the person a job.
            borrowers, to consent to installation of starter-in-  Numerous applications of big data and machine
            terrupter devices (SIDs) or other tracking devices in   learning are being introduced in financial services,
            their cars when providing a loan. SIDs have the prac-  including:
            tical benefit of supporting enforcement of reposses-
            sion rights by enabling the lender to disable a vehicle   •  risk assessment, whether for lending or insurance,
            if the borrower defaults on the loan. At the same time,   as discussed above, by companies such as Com-
            they and other tracking devices supply data such     pare.com; 38
            as daily driving activities and locations which allow   •  investment portfolio management “robo-advis-
            inferences about home and work addresses, whether    ers” such as Betterment  and Wealthfront  that
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            the person is still driving to a regular place of employ-  rely on algorithms to calibrate a financial portfolio
            ment (and so employment status), where the person    to a consumer’s investment goals and tolerance
            likes to shop or be entertained, and departures from   for risk;
            habits that may indicate changes in preferences.   •  high-frequency trading (HFT) by hedge funds and
            Tracking devices may also supply data about driving   other financial institutions such as Walnut Algo-
            behaviour patterns that indicate not only skill levels   rithms  and Renaissance Technologies  that use
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            but sometimes even a particular emotional or mental   machine learning for making trading decisions in
            state (e.g., repeatedly accelerating unusually quickly,   real time; 43
            or breaking unusually abruptly).                   •  asset management, liquidity and foreign currency
               Today, a substantial market in inferences about   risk and stress testing;
            people now exists, and how these are generated and   •  fraud  detection  by  companies  like  APEX  Ana-
            used  is  discussed  in  the  next  section.  Overall,  the   lytics  and Kount  through detection and flag-
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            relation between artificial intelligence and big data   ging of unique activities or behaviour anomalies
            is “bi-directional.” Big data relies on artificial intelli-  to block transactions and for security teams to
            gence and machine learning to extract value from     investigate; and
            big datasets, and machine learning depends on the   •  a host of services such as security and digital
            vast volume of data in order to learn. 36            identification, news analysis, customer sales and
                                                                 recommendations, and customer service. 46
            2�3  What are profiling and automated decisions?
            Big data, machine learning and artificial intelligence   In some cases, these new uses are supported by
            (AI) are enabling profitable commercial opportuni-  legislation expressly authorising the use of artificial
            ties and social benefits through profiling and auto-  intelligence. For instance, Mexico’s fintech reforms in
            mated decisions.                                   2018 amended the Securities Market Law to allow for
               Profiling is the automated processing of personal   special rules for automated advisory and investment
            data to evaluate, analyze or predict likely aspects of   management services (also known as robo-advis-
            a person's interests, personal preferences, behaviour,   ers). 47
            performance at work, economic situation, health,
            reliability, location or movements.  Data analytics   2�4  What is consumer protection?
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            enables the identification of links between individu-  Consumer protection is designed to protect humans
            als and the construction of group profiles.        where  they  are  vulnerable.  These  may  include
               Such inferences and predictions may be used     protection of children, the elderly, and others who
            for targeted advertising, or to make  automated    cannot protect themselves for physical or psycho-



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